The Centers for Medicare & Medicaid Services (CMS) (@CMSGov) has made significant strides in relieving regulatory burdens for providers; supporting the patient-doctor relationship in healthcare; and promoting transparency, flexibility, and innovation in the delivery of care.
In recent years, to continue its commitment to promoting and prioritizing interoperability, CMS has made updates to its quality reporting programs to align with these goals. To better understand the similarities and differences between the Medicare Promoting Interoperability Program and the Merit-based Incentive Payment System (MIPS) Promoting Interoperability performance category for program year 2021, detailed criteria are listed below:
Who is eligible to participate in each program?
- Only eligible hospitals and critical access hospitals can participate in the Medicare Promoting Interoperability Program
- Only Medicare eligible clinicians can participate in MIPS, which is one of two ways to participate in the Quality Payment Program
What criteria are specific to the Medicare Promoting Interoperability Program?
- Performance-based scoring methodology composed of 100 total points available with a required minimum of 50 points
- Query of Prescription Drug Monitoring Program (PDMP) measure is worth five bonus points
- Electronically report on an additional four of nine clinical quality measures (CQMs)
- Attest through the CMS Hospital Quality Reporting System (also referred to as the QualityNet Secure Portal)
- Hardship exception applications are available after the data submission period has ended
What criteria are specific to the Promoting Interoperability performance category of MIPS?
- One of four performance categories
- 25% of total MIPS score
- Query of PDMP measure is worth 10 bonus points
- Optional Health Information Exchange (HIE) Bi-Directional Exchange measure as an alternative reporting option to the two existing HIE measures
- Ability to submit data manually on qpp.cms.gov, through a file upload on qpp.cms.gov, or through a third-party vendor
- Hardship exception applications are available prior to the data submission period
What criteria must both the Medicare Promoting Interoperability Program and Promoting Interoperability performance category follow?
- Minimum of a continuous 90-day required reporting period
- Required use of (1) existing 2015 Edition certification criteria, (2) the 2015 Edition Cures Update criteria, or (3) a combination of the two:
- Certified electronic health record technology (CEHRT) functionality must be in place by the first day of the EHR reporting period
- EHR must be certified by ONC by the last day of the EHR reporting period
- Must use CEHRT functionality for the full EHR reporting period
- Report on four objectives
- Must submit a “Yes” to:
- The Prevention of Information Blocking Attestation
- The ONC Direct Review Attestation
- The Security Risk Analysis measure
For more information, view the Medicare Promoting Interoperability Program vs. MIPS Promoting Interoperability Performance Category Fact Sheet. Additionally, visit the Promoting Interoperability Programs website and the Quality Payment Program website for additional resources.
To learn more about the 2015 Edition Cures Update, please review the Office of the National Coordinator for Health Information Technology’s 21st Century Cures Act final rule. To check whether a health IT product has been certified to the 2015 Edition Cures Update criteria, visit the Certified Health IT Product List. For information on the Physician Fee Schedule final rule in which the timeline and execution plan for the 2015 Edition Cures Update was finalized for the Medicare Promoting Interoperability Program objectives and measures, please go here.